1 DOCKET NO: A-98-49

Item: II-B3-116



### 2011 -- Emplacement Inspection Report

EPA INSPECTION No. EPA-WIPP-5.11-10c

OF THE

WASTE ISOLATION PILOT PLANT May 10 – May 12, 2011

U. S. ENVIRONMENTAL PROTECTION AGENCY

Office of Radiation and Indoor Air Center for Waste Management and Regulation 1200 Pennsylvania Avenue, NW Washington, DC 20460

October 20112 Contents

1.0 Executive Summary....................................................................... 4

2.0 Inspection Purpose and Scope............................................................. 5

3.0 Inspection Team, Observers and Participants........................................... 5

4.0 Performance of the Inspection............................................................. 6

5.0 Waste Emplacement/WDS............................................................... 7

6.0 Magnesium Oxide Backfill................................................................. 10

7.0 Comparison with Inventory limits............................................................13

8.0 Summary of Results...........................................................................14

Attachments

Attachment A – Inspection Plan.......................................................................16

Attachment B – Summary of Waste Empl acement Inventory Report, July 1, 2011 17

Attachment C - Materials Emplaced in WIPP as of ...............................................19

Attachment D – WDS bar code read er displaying MgO Balance for ...........................20

Attachment E – Procedures Examined................................................................22

Attachment F – Inspection Checklist..................................................................23

Tables

Table A Inspection Participants................................................................ 6

Table B Waste Containers Reviewed During Inspection...................................9

Table C Emplaced CPR Quantities as of ....................................................143 Figures

Figure 1 Typical RH and CH TRU Mixed Wa ste Disposal Configuration ...............8

Figure 2 Arrangement of dis posed waste in a room ..........................................9

Figure 3 Photo of disposed waste in ..................................... 11

Figure 4 Equipment prepared for RH waste emplacement in ...... 12

Figure 5 Emplaced RH Waste selected for review............................................13

.4 1.0 EXECUTIVE SUMMARY

The U.S. Environmental Protection Agency (EPA or the Agency) conducted an inspection of the U.S. Department of Energy’s (DOE ) Waste Isolation Pilot Plant (WI PP) near Carlsbad, New Mexico, from May 10 through May 12, 2011, in accordance with 40 CFR 194.21. The WIPP is a disposal system for defense-related transuranic (TRU) wa ste as defined by the WIPP Land Withdrawal Act. 1
EPA certified that WIPP complies with the Agency’s radioactive waste disposal regulations (Subparts B and C of 40 CFR Part 191) on May 18, 1998.

The purpose of this annual inspection is to determin e that waste sent to WIPP during the past year has been emplaced in the underground facility in the manner specified in DOE’s Compliance Certification Application and other approvals. The inspection reviews the site’s ability to receive, process, and emplace contact-handled and remote-h andled TRU wastes within the repository, the emplacement of magnesium oxide (MgO) backfill in appropriate amounts to fulfill DOE commitments and requirements, and the maintenance of record s pertaining to waste shipping, packaging, and emplacement, including the electronic Waste Data System (WDS). EP A examined selected activities, such as RH and CH waste processing, waste emplacement activities, and record keeping.

EPA concluded that DOE’s emplacement activities ar e adequate, that cellul osic, plastic and rubber material (CPR) is appropriately tracked and record ed, that MgO balances ar e calculated properly, and that MgO is emplaced properly. EPA observed the us e of the proper waste emplacement procedures in the underground and successful implem entation of the WDS bar code re ader. EPA did not identify any findings or concerns during this inspection.

1 WIPP Land Withdrawal Act, Public Law 102-579, Section 2(18), as amended by the 1996 WIPP LWA
Amendments, Public Law 104-201.5 2.0 INSPECTION PURPOSE AND SCOPE

The purpose of this annual inspection is to veri fy that contact-handled (CH) and remote-handled (RH) transuranic (TRU) waste sent to WIPP during the past year has been emplaced in the underground facility in the manner specified in DOE’s Complian ce Certification Applicati on (EPA Air Docket A-93- 02, Item II-G-01) and other approvals. EPA perform ed this inspection under the authority of 40 CFR 194.21, which authorizes the Agency to inspect WIPP during its operational period to verify continued compliance with EPA’s WIPP Compliance Criteria and the certification decision of May 18, 1998. Emplacement of waste and backfill, in particular, is relevant to compliance because the emplacement method supports the models that DOE uses in the WIPP performance assessment.

The primary focus of this year’s inspection was to evaluate the changes relative to the emplacement activities, particularly with regard to the handling and emplacement of the Standard Large Box (SLB II) and documentation sinc e the annual inspection of 2010.

Activities within the scope of this inspection included: demonstration of the WIPP site’s ability to receive, process, and emplace remote-handled (RH) and contact-handled (CH) TRU wastes within the repository, the use of magnesium oxide (MgO) backf ill in amounts to fulfill ce rtification requirements and other approvals, maintenance of relevant waste packaging records, including the electronic Waste Data System (WDS) and the verification of appropriately implemented quality assurance practices. The

review and examination of documents related to thes e activities is an important part of the inspection process. The WIPP site is operated by Washingt on TRU-Solutions (WTS) under contract to DOE, and the majority of waste related activ ities onsite are describe d by or controlled through WTS procedures. A list of WTS procedures examined during this inspection is provided in Attachment G.6 3.0 INSPECTION TEAM, OBSE RVERS, AND PARTICIPANTS

The inspection team consisted of three EPA staf f. Thomas Kesterson and Julia Marple of the New Mexico Environment Department observed the in spection activities. A partial list of inspection participants is provided in Table A.

Table A Inspection Participants

4.0 PERFORMANCE OF THE INSPECTION

The inspection took place from May 10 to Ma y 12, 2011, at DOE’s Carlsbad Field Office (CBFO) and at the Waste Isolation Pilot Plant (WIPP) facility, which is located approximately 26 miles south east of Carlsbad, New Mexico. The opening meeting with CBFO and WTS personnel was held on the morning of May 10, 2011. Several DOE and WTS staff presented information addressing program status, updates and changes since the last EPA emplacement inspection which took place from June 29 to July 1, 2010. The primary focus of emplacement insp ection was to determine the nature and extent of changes taken place in the areas of emplacement activities and documentation since last year’s inspection, particularly with regard to the handlin g and emplacement of the Standard Large Box (SLB II). In the opening meeting Ed McGary presented th e status and results of MgO program at the WIPP.

EPA inspectors accompanied CBFO and WTS personnel into the underground repository on the morning of May 11, in order to examine waste packag es and MgO that had been emplaced in Panels 5 and 6. Inspectors reviewed paper records documen ting that waste emplacement and MgO tracking were conducted in accordance with procedures. Inspectors selected several containers and recorded their numbers (see Figure 3 for container locations); the records for these c ontainers were examined both in INSPECTION TEAM

MEMBER POSITION AFFILIATION

Tom Peake Inspector EPA ORIA Jonathan Walsh Inspector EPA ORIA Kathleen Economy

Nick Stone

Shankar Ghose Inspector Inspector Inspector EPA ORIA EPA Region 6

EPA ORIA

Gene Valett WTS Rey Carrasco WTS

Art Chavez Mark Dziamski/Craig Suggs WRES

WTS Dan Ferguson CBFO

Chris Luona WTS Dave Speed WTS David Squires WTS

Mike Strum WTS7 the repository, and later using the WDS computer da tabase, to verify correct waste information is recorded by DOE. WTS personnel answ ered EPA questions about how wast e is handled and emplaced. The inspectors also examined air monitoring loca tions, and observed the measurement of geotechnical parameters and mining in Panel 7.

During the afternoon of May 11, EPA inspectors obs erved operations CH and RH bay areas of the waste handling building aboveground. Also on Ma y 11, inspectors remotely accessed the WDS, and were able to generate Containe r and Canister Data Reports for the RH boreholes and CH waste containers observed in the underground that morning. On the morning of May 12, inspectors discussed record-keeping procedures with WDS data administ rators at the Carlsbad Field Office, and WTS personnel generated additional report s and queries for the inspectors. EPA presented its preliminary observations at a close-out meeting on the afternoon of May 12.

5.0 WASTE EMPLACEMENT/WDS

Wastes received at the repository include contac t-handled (CH) transuranic wastes from Argonne National Laboratory-East (ANL-E) in Illinois, Los Alamos National Laboratory (LANL) in New Mexico, Idaho National Laboratory (INL), Hanford Site in Washi ngton, Rocky Flats Environmental Technology Site (RFETS) in Colorado, Savannah River Si te (SRS) in South Carolina, the Nevada Test Site (NTS) in Nevada, and the Oak Ridge National La boratory (ORNL) in Tennessee. These wastes are received and emplaced in several configurations : Standard Waste Boxes (SWBs), 55-gallon drums assembled in groups of seven called a Seven Pack, 100 gallon drums for supercompacted waste, and Ten Drum Overpacks (TDOP). RH wastes from INL, ORNL, and SRS have been emplaced in the WIPP, using the 72-B canister.

The repository is subdivided into panels, each pa nel consisting of seven rooms. At the time of the inspection, CH waste was being emplaced in Panel 5, Room 1 and RH waste in the walls of Panel 6,

Room 7. CH waste containers are stacked in column s (waste stacks) combining SWBs, drum packs, and TDOPs (see Figures 2 and 3). TDOPs are always pl aced on the floor of the room, occupying the bottom and middle position of a waste column. SWBs and dr ums may be emplaced in any order, with most wastes emplaced as received. The waste columns are in a series of staggered rows, with a row consisting of three columns that span the distance of a disposal room from left to right (Figure 2). RH waste is placed in the walls on eight f oot centers (Figures 1, 4, and 5).8 Figure 1 Typical RH and CH TRU mixed waste disposal configuration9 Figure 2 Figure 2 Illustrates the arrangement of disposed contact-h andled waste in underground. Represented are stacks of seven-packs of drums and standard waste boxes.

In Panel 6, Room 7 inspectors observed bore holes drilled to emplace RH containers, and observed the Horizontal Emplacement/Retrieval Equipment set up to emplace a RH canister (Figure 4).

While underground in Panel 5, Room 1, EPA inspect ors selected recently emplaced CH waste packages for review. The inspector noted the shipment identification numbers as read by the underground escort directly off the emplaced containers (See Figure 3 for CH locations). The containers

selected are identified in Table B below.

Table B: Waste Containers Reviewed During Inspection

CH Waste Containers Reviewed During Inspection (Panel 5, Room 1) Container Number Container Type BN10404666 Ten Drum Overpack (TDOP) BN10399691 7- pack LASB01179 Standard Waste Box (SWB) BW10400132 55-gallon drum

RL0062383 55-gallon drum RL0070588 55-gallon drum

RH Waste in Selected Boreholes (Panel 5, Room 1) Container Number Borehole

AE0085 043

BC0017 051

Since the last inspection, DOE informed EPA of plans to emplace CH wa ste in the repository using a new container, the Standard Large Box, or SLB-II. The SLB-II requires the use of a new shipping container, the TRUPACT-III. At the time of this inspection, no waste had been shipped to WIPP using the SLB-II. While in the Waste Handling building on May 11, EPA inspectors observed the10 construction and testing of specializ ed robotic equipment, including th e Yard Transfer Vehicle, which

will be used to move and unload the TRUPACT-III in preparation for emplacement of the SLB-II. An EPA inspector returned to observe a demonstration of this equipmen t and implementation of relevant procedures on June 14, 2011. EPA will continue its ov ersight to verify that the emplacement of waste using the SLB-II is conducted appropriately.

On the morning of May 12 at CBFO, inspecto rs met with WTS personnel, who answered questions and generated the Nuclide Report, Wast e Emplacement Report and the MgO safety factor

calculations. All electronic records were found to contain required waste stream, container, and emplacement information.

6.0 MAGNESIUM OXIDE BACKFILL

` Magnesium oxide (MgO) is the engineered barrier used in the repository as backfill, as specified in DOE’s Compliance Certification Application (CCA). EPA requires DOE to maintain an MgO safety factor (excess factor) to ensure that adequate MgO is chemically available to control the chemistry of each room after closure. EPA approved lowering the required safety factor to 1.2 from 1.67 in a letter dated February 11, 2008, requiring the emplacement of sufficient MgO to react with 1.2 times the amount of carbon present in the repository. Conditi ons of EPA’s agreement stipulate that DOE must ensure a minimum reactivity of 96% for the MgO emplaced, and maintain the safety factor on a roomby-room basis. DOE instituted this change in March 2009, and it was a focus of EPA’s 2009 inspection.

During the opening meeting, Edward McGary an d Gene Valett gave a presentation updating DOE’s MgO Program and management. Th e following information was provided:

 MgO bulk shipment deliveries from Manistee, Michigan continue on an as-needed basis.

.

 The local bagger vendor (Questa Fertilizer, Loving, NM) continues with super sack

deliveries on an as needed basi s (Generally delivered weekly).

 The lab of record (ALS Laboratory Group, Fort Collins, Colorado) continues to conduct reactivity analysis sample tes ting on an as needed basis or whenever bulk shipment of MgO is requested.

 All necessary documentation for the MgO program continues according to the RIDS documentation system.

 No technical changes to the program sin ce the last EPA Annual WIPP Inspection in

2010.

 Reactivity results since last visit:

1. Average reactivity from June 29 th - September 30 th was 97.3% (June 29 th EPA Annual WIPP Inspection for FY 2010).

2. Average reactivity from October 25 th - February 15 th was 98.0

3. The average reactivity for the above is 97.65.

Process steps guiding MgO placement and documentation in the underground continue to be found in WP 05-WH1025, CH Waste Downloading and Emplacement , and WP-05-WH.02, WIPP Waste Handling Operations WDS User’s Manual

. Waste Handling Engineers (W HE) may record the quantity and placement of MgO electronically using a WWIS/WDS bar code reader, or manually via paper forms11 if a bar code reader is unavailable. The appr opriate forms (CH Waste Downloading and Emplacement Data Sheet and Supersack/BRT Emplacement Data Sh eet) are included as Attachments 1 and 3 of WP 05-WH1025. While in the underground repository, EPA in spectors verified that the proper procedures were used to track MgO emplacement in Panel 5, Ro om 1 and that MgO was emplaced on top of the CH waste stacks as stipulated. At the conclusion of each shift, the WHE must electronically verify the safety factor of 1.2 using the WDS. MgO safety factor calculations made using the WDS allowed inspectors to verify that a MgO safe ty factor in excess of 1.2 is being ma intained in Panel 5, Room 1.

Checklist items 12-17 and 24 specifically relate to MgO management and demonstrate that DOE has appropriate processes in place to ensure that MgO is properly emplaced.

DOE is emplacing waste stacked 2-3 containers high topped with MgO Supersacks. Figure 3 shows all container types being sh ipped to date. Large drums are Ten Drum Overpacks (TDOPs), black barrels are 100-gallon drums with supercompacted wa ste, smaller white contai ners are standard waste boxes, and standard 55-gallon drums appear in 7-packs. 3000 lb Mg O supersacks are visible on top of

the stacks.

Figure 3 . Emplaced waste in Panel 5, Room 1.12 Figure 4 Equipment prepared for RH waste emplacement in Room 7 of Panel 6

Figure 5 Emplaced RH Waste selected for review13 7.0 COMPARISON WITH INVENTORY LIMITS

In the Summary of Waste Emplacement Inventor y Report, available through the EPA dashboard, EPA was provided data for emplaced waste, incl uding total activities of the ten EPA-tracked radionuclides, total weights of ferrous and non-ferrous metals, and the CPR/MgO balance by room, as of April 7, 2011. More detailed data on the total amounts of specific materials emplaced was provided by WDS staff, using a script to run a custom WDS query.

EPA establishes limits for certain waste components at WIPP by approving performance assessment inventory estimates. Some limits, such as for iron and other metals, are minimum limits. The amount of iron and steel are now at 21,762,561kg. The minimum limit of 2 x 10 7 kg iron has now been met for the repository. Other waste component limits are maximum limits. Of special concern is the maximum limit on the total amount of cellulosic, pl astic and rubber (CPR) materials. In the original CCA, DOE calculated 2.2 x 10 7 kg of CPR, establishing EPA’s limit. In the subsequent performance assessment baseline calculations, DOE added packag ing materials to the calculations, and now the CPR

limit for WIPP is 2.4 x 10 7 kg (see Table C). CPR values are tracked on a per container basis and the current CPR values as of March 31, 2011are listed in Table C.

As of this inspection the WIPP contai ned almost 5,429,253.20 kg of CPR in waste and 1,540,281.56 kg of CPR in packaging material. In additi on, emplacement CPR, such as the slip sheets used to aid the emplacement of the containers, accounts for another 437,035.28 kg of CPR. This is a total of 7,406,570.04 kg of cellulosic, plastic and rubber material. The mass of rubber materials currently accounts for approximately 4.7% of the total mass of CPR, compared to 4.3% in 2010, 3.4% in 2009, 5% in 2008, 4.7% in 2007, and 7% in 2006. The WIPP currently contains approximately 30% of its maximum limit for CPR. The repository held 29% of its limit for CPR in 2009, 24% in 2008, and 21%

in 2007. Table C: Emplaced CPR Quan tities as of March 31, 2011

Waste CPR: Emplacement CPR: Type Weight (kg) Type Weight (kg)

------------------ --------------- --- ------------- ------------- ------ Cellulosic 2,163,373.94 Cellulosic 55,562.08 Plastic 2,940,275.48 Plastic 381,473.20 Rubber 325,603.78
Total 5,429,253.20 (kg) 437,035.28 (kg)

Packaging CPR: MgO CPR: Type Weight (kg) Type Weight (kg)

------------------ --------------- -- ------------- ------------- ------ Cellulosic 854,938.96 Cellulosic 53,202.45 Plastic 685,342.60 Plastic 58,849.95 Total 1,540,281.56 (kg) 112,052.40(kg)

Grand Totals: Cellulosic + Plastic = 6,643,930.98 Rubber = 325,603.78

Total CPR = 6,969,534.76 (kg)14 8.0 SUMMARY OF RESULTS

The inspectors reviewed emplacement operations , WTS procedures, and records associated with selected containers. The surface processing of CH and RH waste as well as underground operations were reviewed and found to be adequate, accordi ng to specified plans documented in the CCA. EPA concludes that DOE’s emplacement activities and r ecords are adequate, and that CPR and MgO are appropriately tracked. EPA identified no findings or concerns with the emplacement portion of the inspection.15 Attachment A WIPP Emplacement Inspection Plan for the year 2011

Purpose: The purpose of this inspection is to verify that waste sent to WIPP during the past year has been emplaced in the underground facility in the manne r specified in DOE’s Compliance Certification Application (EPA Air Docket A-93-02, It em II-G-01) and other approvals.

EPA is performing this inspection under the authority of 40 CFR 194.21, which authorizes the Agency to inspect the WIPP during its operational pe riod to verify continued compliance with EPA’s WIPP Compliance Criteria and the ce rtification decision of May 18, 1998.

Scope: The scope of this inspection includes: demonstrati on of the site’s ability to receive, process, and emplace contact-handled and remote-handled TRU wast es within the repository; the use of magnesium oxide (MgO) backfill in appropriate amounts to fulfill DOE commitments and requirements; maintenance of relevant waste packaging records, including the electronic WIPP Waste Data System (WDS) and the verification of appropriately implem ented quality assurance practices. The availability of documentation of these processes and activ ities will be a major source of review.

Focal Areas for this Year’s Inspection: What changes have taken place to emplacement ac tivities and documentation since last year’s inspection, particularly with regard to the handlin g and emplacement of the Standard Large Box (SLB II)?

Location: The inspection will be held at DOE’s WIPP f acility located twenty-six miles southeast of Carlsbad, New Mexico and the Carlsbad Field Offi ce (CBFO) in Carlsbad. Inspection activities will include examination of the underground facilities, review of records related to waste emplacement, and

other information as needed.

Duration: The EPA expects to complete its inspection in three days, plus a return visit to view the Integrated Facility Checkout (w hich will demonstrate the handli ng of the TRUPACT-III and SLB.) Each full day will begin with an opening meeting at 8:00 a.m. and end no later than 5:00 p.m. with a

closeout session.

Date: May 10-12, 2011

Documents for Review: Provide to EPA the latest version of pertinen t documentation and/or proc edures related to CH and RH waste handling and emplacement, MgO empl acement and tracking, and record keeping using

the WDS.16 Attachment B

Summary of Waste Emplacement Inventory Report April 07,201117 Attachment C

Materials Emplaced in WIPP as of March 31, 2011

CH WASTE:

MP Material Type Material Desc ription Ma terial Weight (kg)

1 Waste Iron Based Metal/Alloys 8,126,957.56 2 Waste Aluminum Based Metal/Alloys 49,165.30 3 Waste Other Metal/ Alloys 302,070.50 4 Waste Other Inorganic Materials 1,500,109.98 6 Waste Cellulosics 2,163,373.94 7 Waste Rubber 325,603.78 8 Waste Plastics 2,940,275.48 9 Waste Solidified Inorganic Material 6,808,062.69 10 Waste Solidified Organic Material 1,936,185.60 12 Waste Soils 475,200.43

13 Steel - Packaging Steel Container Materials 13,338,733.73

14 Plastic - Plastic /Liners Container Packaging Materials 685,342.60 15 Cellulosic - Cellulosic Packaging Packaging Materials 854,938.96 18 Emplacement Cellulosic Emplacement Material 55,562.08 20 Emplacement Plastic Emplacement 381,473.20

Material

RH Waste:

1 Waste Iron Base Metal/Alloys 48,890.19 2 Waste Aluminum Base Metal/Alloys 29.20 3 Waste Other Metal/Alloys 9.72 4 Waste Other Inorganic Materials 13.06

6 Waste Cellulosics 71.10

7 Waste Rubber 7.30 8 Waste Plastics 51,720.11 9 Waste Solidified Inorganic Ma terial 194.55 10 Waste Solidified Organic Material 15.06

13 Steel Steel Container Materials 247,898.44 Packaging

14 Plastic Plastic/ Liners Container Packaging Materials 403.86 15 Cellulosic Cellulosics Packaging 4.26 Packaging Materials18 MgO

16 Emplacement Magnesium Oxide 28,581,798.99 18 Emplacement Cellulosic Emplacement Mat’l 53,202.45 20 Emplacement Plastic Emplacement Mat’l 58,849.95

Totals: 69,141,167.0719 Attachment D WDS bar code reader displaying MO Balance for Panel 5, Room 420 Attachment E

Procedures Examined21 Attachment F EPA Emplacement Inspectio n Checklist – May 10-12, 2011

# Questions: Comments and Objective Evidence Results

Waste Emplacement

1 Is waste being emplaced in the underground facility in the manner specified in DOE’sCompliance Certification/ ReCertification or other relevant

documentation? Yes. Procedure WP 05-WH1025, CH Waste Downloading and Emplacement, Section 2, describes the CH emplacement procedures. Visual verification of the emplaced waste in Rows 146 through 148 of Panel 5, Room 4 confirmed waste emplacement in accordance with facility procedure and CCA

documentation .

RH processing procedures for 72-B (WP 05-WH1710, WP 05-WH1725) and 10-160-B (WP 05-WH1722) containers are consistent with the approach discussed in the CCA documentation. Emplacement in the repository walls with borehole plugs was verified during inspection of the underground. Satisfactory

2 Are CH waste containers stacked in columns appropriately given the type of container? Yes. In WP 05-WH1025, CH Downloading and Emplacement, a note at step 2.25 specifies appropriate stacking of CH container types. Attachment 2 of the same procedure specifies payload assembly positioning. Visual verification confirmed adherence to procedure (e.g. TDOPs placed in bottom position of waste columns.) Satisfactory22 3 Are records adequate?

Randomly select 3-4 CH and 2-3 RH waste containers to verify records for waste approval, shipment, and receipt. Yes. TRU Waste Receipt WP 08-NT3020, Rev.18 describes the process. Reco rds produced are Uniform Hazardous Waste Manifest, TRU Waste Receipt Checklist, Shipment Summary Report, RH waste Processing Data Sheet, Radiological Survey Report, and Waste Emplacement Report. CH waste produces comparable records. EPA reviewed records and found the records to be adequate and traceable.

Selected Containers:

CH Waste (Panel 5, Room 1, Rows 16-17)
- Ten Drum Overpack (TDOP), BN10404666 - Standard Waste Box, (SWB), LASB01179 - Standard Waste Box (SWB), LASB01171 - 100-gallon drum, BN10368262 - 55-gallon drum, RL0062383

RH Waste (Panel 6, Room 7) - Borehole 051, BC0017 (55 gallon drum)

RH Waste (Panel 6, Room 7) - Borehole 043, AE 0085 (RH CANISTER WITH REMOVABLE LID-OVERPACK) Satisfactory

4 Is DOE properly emplacing backfill material (magnesium oxide [MgO]) with the waste packages?

Are supersacks placed on top of waste stacks according to procedure? Yes. 3000-pound supersacks were observed to be emplaced on top of each waste assembly at the active waste face in Panel 5 Room 1. WP 05-WH1025, CH Waste Downloading and Emplacement, Section 3.0, establishes procedure for emplacement of MgO. Satisfactory

5 Verify documentation for the

containers listed in item 3 - waste generator site transmittal of waste to WIPP, WIPP approval, shipment certification for transport to WIPP, shipment initiation documentation, shipment received at WIPP records, waste emplaced in the underground, and placement of engineered barrier [MgO]. Inspectors examined paper records maintained underground and electronic records kept aboveground for the selected containers. Site operators

demonstrated the use of the WDS bar code reader to track emplacement of waste and MgO. Documentation was determined to be adequate. Satisfactory23 RH Waste Emplacement Questions

6 Are RH containers approved for receipt, received, processed, and emplaced properly? Yes. Inspection of the underground and RH handling area showed procedures to be in agreement with WP 05-WH1710, 72-B RH Processing, and WP 05- WH1725, RH Waste Downloading and Emplacement. Satisfactory.

7 Are RH containers appropriately

tracked?

Where is the information?

--In the WDS, what report

--During the receipt/transfer process where is it recorded?

--In the underground? Yes. Appropriate information is found in the WDS Canister Data Report, a nd on the underground facility map maintained by the Waste Handling Engineers in the underground. Satisfactory.

8 Content of RH canisters

--pick 1 to 3 canisters See Item 3 above. The Canister Data Report was generated and reviewed for each canister. Satisfactory

9 Volume and mass and/or concentration of important waste components and radionuclides (RH and CH)?

Are they within statutory and regulatory limits? Detailed description of nuclide information is included in the Waste Container Data Reports and Canister Data Reports generated.

Yes. Satisfactory

10 Are RH boreholes closed properly?

(Note: also see #9 for tracking of RH in the U/G) Recently emplaced borehole plugs, and plugs prepared for emplacement, were observed by inspectors in the underground to be in accordance with WP 05- WH1725, Rev. 3, RH Waste Downloading and Emplacement. Satisfactory

11 Is a photographic record made of the RH canister number during emplacement and retained in the permanent record? No. The canister ID number is verified by two operators during cask transfer, via closed-circuit television in accordance with procedure 05-WH1710, 72-B RH Processing, Section 8.24. WTS personnel provided EPA inspectors with screen shots from this process. Tapes are maintained for one year, and WP 05-WH1710 Att. 1, RH Waste Processing Data Sheet, then becomes the permanent r ecord. EPA finds this to be adequate. Satisfactory24 Question: Procedure

12 Do DOE procedures reflect an MgO safety factor to 1.2? Partially. WP 05-WH1025, CH Waste Downloading and Emplacement, Rev. 1, Section 3.0, Backfill, establishes procedures to maintain a safety factor of 1.2 or greater per room on a daily basis. Procedures in the WDS User’s Manual, WP-05-WH.02, Rev. 0, Sections 6.2.5, 9.5.3, and Attachment 1 reflect the 1.2 safety factor and the use of 3,000-lb. supersacks as necessary. WHEs were observed to be using current procedures and the WDS bar code reader to record MgO emplacement in the underground. Satisfactory

13 Are both CPR and MgO

calculated and tracked on a roomby-room basis? Yes. Calculations are performed by the Waste Handling Engineer at the conclusion of each shift, through the WDS, using the MgO Balance Report or Daily Report, as required by WP 05-WH1025, CH Waste Downloading and Emplacement, Rev. 1, Section 3.0, Backfill. Satisfactory

14 Are sampling and analytical procedures in place to ascertain that emplaced MgO maintains a minimum of 96% reactivity? Yes. Specification D-0101, Prepackaged MgO Backfill, Rev. 8 and WP 05-WH1105, MgO Sample Records Management, Rev. 0, set forth analytical and document management procedures to verifying that each shipment of MgO maintains a 96 +/- 2% reactivity. Average reactivity from October 25 th (2010) - February 15 th (2011)was 98.0 The average reactivity for the above is 97.65. Satisfactory

15 Is the acceptance of the MgO backfill material from the supplier

documented? Yes. WP 05-WH1105, MgO Sample Records Management, Rev. 0, Sec. 2.0 requires each shipment to be numbered, and the MgO supplier to provide an Analysis of Shipment and a sample under Chain of Custody for each shipment. Supersacks in the underground were observed by inspectors to be marked with unique ID numbers, traceable to their original shipments. Satisfactory

16 For the MgO needed for high CPR, are there procedures or

documentation for the WHE or WHM (or other appropriate personnel) identifying when and

where additional MgO is needed? Yes. General procedures are found in the WIPP Waste Handling Operation WDS User’s Manual, WP 05–WH.02, Attachment 1, Special Requirements for Additional MgO. Section 3 of WP 05-WH1025 calls for notification of the WHM if daily reports show the MgO safety factor of a room to be less than 1.2. Satisfactory

17 Is there documentation that

identifies how MgO should be placed with high CPR waste? Yes. WP 05-WH1025, CH Waste Downloading and Emplacement, Attachment 3, Supersack/BRT Emplacement Data Sheet; and WP 05-WH1058, CH Waste Handling Abnormal Operations, Sec. 4.0, BRT Emplacement Satisfactory25 18 Verify documentation of procedures for abnormal operating conditions, and documentation of training for contingencies. Abnormal operating and emer gency procedures were reviewed, including but not limited to those listed

below.

WP 04-CO, Conduct of Operations, Rev. 11, identifies notification policies, supervision and training procedures, and required reading (Management Policy 1.30).

WP 02-EC3506, Environmental Incident Reporting, is the Management Control Procedure for reporting releases, and includes statutory requirement charts for

notifications and decision flowcharts.

WP 05-WH1058, CH Waste Handling Abnormal Operations, includes instructions for recovering from a torn slip sheet, moving emplaced waste, returning waste to surface, and emplacing BRTs. Specifies that “Abnormal operations of a large scope (e.g. overpack and retrieval) will have specific plans developed.” WP 05-WH1758, RH Waste Handling Abnormal Operations, includes instructions for operating the Hot Cell Crane in response to a hoist, trolley, bridge or grapple failure, installing and removing the Waste Transfer Machine Assembly (WTMA) wheels, retrieving a loaded RH –TRU 72-B Cask from the Transfer Cell, returning a loaded 10-160B Cask to a generator site and resetting the Transfer Cell Light

Curtain.

WP 12-9, WIPP Emergency Management Program, is the top-level document outlining emergency response procedures and responsibilities, includes training requirements for response roles.

WP 05-WH4401, Waste Handler Operator Event Response, includes alarm, alert, and exit procedures.

WP 12-ER3906, Categorization and Classification of Operational Emergencies includes tables of procedures for emergency notifications and

classification of events.

WP 12-HP4000, Emergency Radiological Control Responses, provides guidance for responding to an actual or suspected breach of a TRU container, contamination found outside controlled areas, radiation levels exceeding the limits set in WP 12-5. Satisfactory26 # Question : Records/WDS

Do the characterization module, certification module, shipping module, and inventory module adequately record required

information? WWIS modules have been replaced by WDS Dashboards. Reports available through the EPA Dashboard contain the container number, shipment number, emplacement data and underground location. EPA staff queried the WDS to verify that this information is recorded correctly. Satisfactory

19 Does the WDS adequately document waste shipment and emplacements information for waste containers selected? (Item 3 above) CH, RH Yes. Canister, Overpack, and Container Data Reports were retrieved, all of which correctly reflected container number, shipment number, and emplacement information in the underground. Satisfactory

20 Do records verify that contact

handled waste container surface doses fall within statutory requirements? Where are CH

surface dose records maintained? Yes. CH surface dose measurements are recorded in the Container Data Report. Dose limits for each of the containers examined by EPA inspectors (listed in Item 3) were below statutory limits. Satisfactory

21 Review a Waste Container Data Report. Does this report adequately record the Waste

Stream Profile Form information? Yes. For all containers inspected, inspectors found Container and Canister Data Reports to contain Waste Stream IDs, as well as all necessary radiological and chemical profile information. Satisfactory

22 Review the Shipment Summary Report. Does the report correctly record the containers shipped? CH, RH By querying the Shipment number, the Shipment Data report may be generated. Inspectors verified that the report reflects the containers shipped. Satisfactory

23 Review the Waste Emplacement Report. Does this report adequately record the date of receipt, and disposal locations of containers? CH, RH Yes. See Item 21. Satisfactory

24 Is DOE assuring that the 1.2 safety factor being maintained on

a room basis?

Does the WDS accurately calculate the safety factor and recommend the proper amount of MgO to emplace? Yes. See questions 12-17.

EPA inspectors reviewed InSEI Matrix Requirements WWIS2-REQ-2126 and -2127 to verify that the WDS software calculates MgO excess appropriately.Documents Received and Reviewed DuringInspectionEmplacement Inspection May 2011Document TitleSubject MatterSourceWP 12-ER4902, Rev. 12, Hazardous Material Spilland Release Respon , 2/02/09Emergency Response Procedure for RCRA event. DOE/WIPPWP 12-ER3906, Rev. 1, Categorization andClassification of Operational Emergencies, 12/5/08Mangement Control Procedure for classifyingemergency and beginning notification within fiteenminutes.DOE/WIPPWP 12-9, Rev. 29, WIPP Emergency ManagementProgram, 7/31/08Comprehensive overview of emergency response,notifications, and reentry.DOE/WIPPWP 08-NT3020, Rev. 18, TRU Waste Receipt,6/9/09, 36 pp.Management Control Procedure for reciept of TRUand mixed wastes, performed by TransportationEngineer. Sets storage and time limits for initialprocessing. Uses 'WDS/WWIS.'DOE/WIPPWP 08-NT.07, Rev. 6, Waste Data System SoftwareDesign Description*, 12/14/09, 17pp.Top level summary of software design andcomponents. Heavily rewritten to reflect WDSchangeover.DOE/WIPPWP 08-NT.06, Rev. 6, Waste Data System SoftwareRequirements Specification*, 12/14/09, 30pp.Summarizes requirements, functions, user roles,constraints, and assumptions of the WWIS. Sec 5.1clearly defines WWIS/WDS relationship.DOE/WIPPWP 08-NT.05, Rev. 7, Waste Data System SoftwareVerification and Validation Plan*, 5/25/10, 16pp.Verification and Validation activities through all lifephases of the WDS. Title updated. No other majorchanges from 2009.DOE/WIPPWP 08-NT.04, Rev. 15, Waste Data SystemConfiguration Management and Software QAProgram*, 12/17/09, 26pp.Delineates QC/Data management responsibilities forall WDS users, accounting and documentaitonprocedures.DOE/WIPPDocuments Received and Reviewed DuringInspectionEmplacement Inspection May 2011Document TitleSubject MatterSourceWP 08-NT.03, Rev. 11, Waste Stream Profile FormReview and Approval Program, 12/10/2009, 17pp.Review procedures for assuring compliance withHazardous Waste Facilities Permit Waste AnalysisPlan, and WIPP Waste Acceptance Criteria,enumerating minimum reviews for each approval.Explains that WWIS is a subset of WDS.DOE/WIPPWP 08-NT.01, Rev. 21 Waste Data System Programand Data Management Plan, 4/14/10Operational overview of WWIS, including regulatoryrequirements, process, and user responsibilities. TiesWDS functions to regulatory requirements.DOE/WIPPWP 05-WH4401, Rev. 3, Waste Handling OperatorEvent Response, 3/21/01Emergency Procedure for CAM alarms, fire, smoke,toxic gas, structural issues, or spill/release.DOE/WIPPWP 05-WH1810, Underground Transuranic MixedWaste Disposal Area Inspections, Revision 13,Effective Date: February 10, 2011Technical Procedure for Preoperational UndergroundTRU Mixed Waste Dispsoal Area Inspections.Inspection checklists included in two attachments.Minor updates to reflect consolidated DSA/TSR.DOE/WIPPWP 05-WH1758, Rev. 7, RH Waste HandlingAbnormal Operations, 12/17/09, 50ppTechnical Procedure for operation of the Hot CellCrane in respose to a hoist, trolley, bridge or grapplefailure, installing and removing the the Waste transferMachine Assembly (WTMA) wheels, retrieving aloaded RH –TRU 72-B Cask from the Transfer Cell,returning a loaded 10-160B Cask to a generator site,or resetting the Transfer Cell Light Curtain. Minorupdates reflect WDS, reference LCOs.DOE/WIPPWP 05-WH1752, Rev. 4, 10-160B Shielded InsertInstallation and Removal, 2/05/09Technical Procedure. CNS 10-160B cask not yet inuse at time of inspection. CCTV use stipulated.DOE/WIPPDocuments Received and Reviewed DuringInspectionEmplacement Inspection May 2011Document TitleSubject MatterSourceWP 05-WH1744, Rev. 11, Surface RH TransuranicMixed Waste Handling Area Inspections, 12/17/2009,20pp.Technical Procedure for RH WHT/WHE to inspectaboveground RH operations. PreoperationalInspection, Daily Door Check, Trailer Parlking Areaand RH Container Storage Area Weekly Inspection,RH Waste Handling Preoperational Inspectionchecklists included as attachments. No major changesin 2010DOE/WIPPWP 05-WH1729, Rev 9, RH-TRU 72-B CaskUprighting Trailer Unloading, 5/20/10, 22pp.See above.WP 05-WH1727, Rev. 8, RH-TRU 72-B CaskUprighting Trailer Loading, 5/20/10, 20pp.Distinct trailer from the mechanically-operated trailerwhich requires the bridge crane.WP 05-WH1726, Rev. 0, RH WasteDownloading/Emplacement Using DistributedControls, 1/19/10, 25pp.Distinction from WH1725 is unclearWP 05-WH1725, Rev. 5, RH waste Downloading andEmplacement, 3/11/10, 25pp.Technical Procedure for RH operations in theunderground. Includes paper RH Waste ProcessingData Sheet. LCOs referenced by number.DOE/WIPPWP 05-WH1722, Rev 11, 10-160B RH Processing,12/17/09, 35pp.Technical procedure for unloading the CNS 10-160Band canisterizing drums into the facility canister.CCTV "if necessary" - 13.0, 14.0Reviewed 6/9/10JPWWP 05-WH1718, Rev. 6, CNS 10-160B TrailerUnloading, 2/19/09Technical procedure. CNS 10-160B cask not yet inuse at time of inspection.DOE/WIPPWP 05-WH1717, Rev. 8, Cask Unloading RoomShield Door Operation, 6/24/09, 7pp.Continuous Use Procedure for operating the CURshield door. Minor updates reflect consolidatedDSA/TSR.DOE/WIPPDocuments Received and Reviewed DuringInspectionEmplacement Inspection May 2011Document TitleSubject MatterSourceWP 05-WH1716, Rev. 4, CNS 10-160B CaskOperation, 6/24/09, 10pp.Technical Procedure for opening 10-160B cask.Includes cask data sheet. CNS 10-160B cask not yet inuse at time of inspection.DOE/WIPPWP 05-WH1714, Rev. 3, RH Cask PreparationStation 41-Z-076, 3/18/10, 6pp.Technical Procedure for preoperational checks of theRH CPS. Pertinent to 10-160B.DOE/WIPPWP 05-WH1713, Rev. 9, Facility Cask and FacilityCask Rotating Device, 6/24/09, 13pp.Technical Procedure for inspection and preoperationalchecksof RH Facility Cask, FC Rotating Device, andHydraulic Power Unit. Minor updates reflectconsilidated DSA/TSR.DOE/WIPPWP 05-WH1712, Rev.3, RH-TRU 72-B CaskOperation, 5/20/10, 10 pp.Technical procedure for opening 72-B Cask. Nomajor changes in 2010.DOE/WIPPWP 05-WH1710, 72-B RH Processing,Revision 21,Effective Date: September 1, 2010Technical Procedure for unloading the 72-B Shippingcontainer and preparing for dowloading to theunderground. Fully revised, WHE Review added.Also see Section 3.3: CCTV recordingDOE/WIPPWP 05-WH1709, Rev. 13, Rh-TRU 72-B TrailerUnloading, 5/20/10Technical Procedure for unloading RH-TRU 72-Bfrom incoming trailer to Cask Transfer Car or storagerack. Npo major changes in 2010.DOE/WIPPWP 05-WH1707, Rev. 9, RH-TRU 72-B TrailerLoading, 6/24/09, 14pp.Technical Procedure for loading RH-TRU 72-B fortransport.WP 05-WH1705, Rev. 8, RH Canister TransferSystem, 6/24/09, 12pp.Technical Procedure detailing preoperationalequipment checks prior to RH waste-handling. 72-Bor 10-160B. CCTV for canister transfer system(sectoion 2.0)Documents Received and Reviewed DuringInspectionEmplacement Inspection May 2011Document TitleSubject MatterSourceWP 05-WH1704, Rev. 7, Facility Cask Transfer Car(41-H-003) Operation, Technical Procedure, Revision7, Effective Date: April 17, 2009Technical Procedure for Facility Cask Transfer Carinspection and RH waste handling - no change in2010.DOE/WIPPWP 05-WH1701, Rev. 10, Road Cask Transfer CarOperation, 2/20/09Technical Procedure for inspection and properationalcheck of The 72-B Road Cask Transfer Car - nochange in 2010.DOE/WIPPWP 05-WH1700, Rev. 11, Horizontal Emplacementand Retrieval Equipment Assembly, Revision 11,Effective Date: January 28, 2011Technical Procedure for setting up the HERE inpreparation for RH canister emplacement. Rewrittento highlight TSRs, LCOs, and SACs by LCO/SACnumber.DOE/WIPPWP 05-WH1105, Rev. 3, Magnesium Oxide SampleRecords Management, 4/19/10, 10 pp.Management Control Procedure for the laboratryverification of MgO reactivity. Example MgOTracking Spreadsheet and Request for Analysisincluded as attachments 1 and 2. No major changes in2010.DOE/WIPPWP 05-WH1058, Rev. 5, CH Waste HandlingAbnormal Operations, 6/2/10, 14pp.Technical Procedure including instructions forrecovering form a torn slip sheet, movement ofemplaced waste, returing weaste to surface, andemplacement of BRTs. Added noncompliant containerresponse, covering filters on assemblies contining highVOCs, and section on WHE review.DOE/WIPPWP 05-WH1025, Rev. 3 CH Downloading andEmplacement, 10/1110Technical Procedure including paper forms forrecording CH Downloading and MgO/BRT placmentas attachments. Updated to reflect both WWIS/WDS.DOE/WIPPDocuments Received and Reviewed DuringInspectionEmplacement Inspection May 2011Document TitleSubject MatterSourceWP 05-WH1011, Rev. 41, CH Waste Processing,2/28/11Continous Use proceedure for unloading TRUPACTII or HalfPACT. Contains forms and sign-offs. Editedto reference WDS, and add LCOs. Section 2.5.31deals with VOCs.DOE/WIPPWP 05-WH1010, Rev. 6, Container Overpacking,12/17/09, 24pp.Technical Procedure for the overpacking ofcontaminated or damaged containers in 85-gallondrum, SWB, or TDOP. Contains documentation forprocedure.DOE/WIPPWP 05-WH.02, Rev. 0, WIPP Waste HandlingOperations WDS User's Manual, 12/17/09, 39pp.Replaces WP 05-WH.01, Rev. 4, WIPP WasteHandling Operations WWIS Users Manual. For useby Waste Handling Technicians and Waste HandlingEngineers. Updated to reflect WDS changeover.DOE/WIPPWP 04-CO, Rev. 11, Conduct of Operations, 10/01/08 Facility operating practices, including shift routines,communications, inspections, training. Minimalchanges to reflect consolidated references (RH/CHDSAs and TSRs) Also document revision control.DOE/WIPPWP 02-EC3506, Rev. 5, Environmental IncidentReporting, 2/26/07Management Control Procedure for reporting releases,including statutory requirement charts and decisionflowcharts.DOE/WIPPWP 02-EC1001, Rev. 8, Characterization Sampling,Shipping, and Documentation, 6/30/08Technical procedure for waste characterization fieldsampling.DOE/WIPPSpecification D-0101, Rev. 8, Prepackaged MgOBackfill, 2/11/09Includes analytical methods to ensure reactivity, andAnalysis Request/Chain of custody forms.DOE/WIPPDocuments Received and Reviewed DuringInspectionEmplacement Inspection May 2011Document TitleSubject MatterSourceDOE/WIPP-09-3427, Waste Data System User'sManual, U.S. DOE, Rev. 2, November 2, 2010Comprehensive guide for all WDS users, includingautomated parameters to verify compliance ofcontainers and shipments with transportaion andemplacement requirements.DOE/WIPP* denotes title updated to reflect WDS changeoverDocuments Received/Generated During InspectionOverpack Data Report, Container No. BN 10404666 (TDOP), CH, Disposal Date: 5/10/11, Panel 5, Room 1. Generated May 11, 2011.Overpack Data Report, Container No. LASB01171 (SWB), CH, Disposal Date: 5/10/2011, Panel 5, Room 1. Generated May 11, 2011.Overpack Data Report, Container No. LASB01179 (SWB), CH, Panel 5, Room 1. Generated May 11, 2011. Overpack Data Report, Container No. BN10399691 (100 GAL DRUM), CH, Panel 5, Room 1. Generated May 11, 2011. Overpack Data Report, Container No. RL0062383 (55 GAL DRUM), CH, Panel 5, Room 1. Generated May 12, 2011,Container Data Report,Container No. 931 (RH 30 GAL DRUM), Panel 5, Room 1. Generated May 11, 2011. Container Data Report, Container No. BC0001 (RH 55 GAL DRUM), Panel 5, Room1. Generated May 12, 2011.Container Data Report, Container No. BC 0017 (RH 55 GAL DRUM), Panel 5, Room1. Generated May 12, 2011.Canister Data Report, Container No. AE0085 (RH Canister with removable lid - overpack), Panel 6, Room 7. Generated May 12, 2011, Nuclide Report. Panel 1, Rooms 1 – 7. Generated May 12, 2011Nuclide Report. Panel 4, Rooms 1&2, Panel 5, Rooms 4, 5 & 6. Generated May 12, 2011,Emplacement History Overview Report, CH, Panel 4, Rooms 1- 7, RH, Panel 4 Rooms 1- 6Nuclide Report, May 12, 2011, Panels 1- 5, Room 1 – 7, Panel 6, Room 7

### Summary of Waste Emplacement Inventory Report Waste Isolation Pilot Plant

Page 1 of 4

Report Statistics

Report Version: 1.2

WDS Instance: PRD01

Generated on: April 07, 2011 03:53 PM

Generated by: RICHEY

Total Pages: 4

Selection Criteria

End Date: 03/31/2011

Panel Number: All

Room Number: All

### Summary of Waste Emplacement Inventory Report RICHEY

April 07, 2011 03:53 PM

Page 2 of 4 

### Waste Isolation Pilot Plant

Total 73,598.79 (m^3)

Panel: All Room: All TRU Waste Inventory as of 03/31/2011

Emplaced CH Containers 73,359.92 (m^3)

Emplaced RH Containers 238.87 (m^3)

Emplaced Container Counts as of 03/31/2011

Description # of Containers Panel: All Room: All

Contact Handled (CH) Container Types

100-GALLON DRUM 26,257

12-INCH PIPE OVERPACK 23,903

55-GALLON DRUM 76,174

85-GALLON DRUM - TALL - OVERPACK 5

S100 PIPE OVERPACK 535

S300 PIPE OVERPACK 10

STANDARD WASTE BOX 5,044

STANDARD WASTE BOX - OVERPACK 4,389

TEN DRUM OVERPACK - OVERPACK 5,448

Remote Handled (RH) Container Types

FIXED-LID 72-B CANISTER 18

REMOVABLE-LID 72-B CANISTER 1

REMOVABLE-LID 72-B CANISTER - OVERPACK 445

Total: 142,229

### Summary of Waste Emplacement Inventory Report RICHEY

April 07, 2011 03:53 PM

Page 3 of 4 

### Waste Isolation Pilot Plant

Material Parameter Inventory

as of 03/31/2011

Material Type Weight (kg) Panel: All Room: All

CELLULOSIC, PLASTIC, RUBBER (CPR) 7,570,829

FERROUS METAL 21,762,561

NON-FERROUS METAL 351,275

OTHER MATERIAL 10,719,781

Total: 40,404,446

EPA-Tracked Radiological Activity Inventory

as of 03/31/2011

Radionuclide Repository CH

Activity (Ci) Repository RH

Activity (Ci) Total Repository

Activity (Ci) Panel: All Room: All

AM-241 2.143E5 2.135E2 2.146E5

CS-137 7.347E0 2.21E3 2.217E3

PU-238 3.243E5 1.002E2 3.244E5

PU-239 2.989E5 1.218E2 2.99E5

PU-240 7.315E4 9.895E1 7.325E4

PU-242 1.691E1 1.213E-1 1.703E1

SR-90 1.355E1 1.789E3 1.803E3

U-233 5.738E0 1.576E-1 5.895E0

U-234 5.933E1 3.198E-1 5.965E1

U-238 1.307E1 9.704E-3 1.308E1

Total 9.107E5 4.534E3 9.153E5

### Summary of Waste Emplacement Inventory Report RICHEY

April 07, 2011 03:53 PM

Page 4 of 4 

### Waste Isolation Pilot Plant

MgO-Related Information as of 03/31/2011

Panel Room MgO (kg) Waste (kg) CPR (kg) Excess Factor Panel: All Room: All

1 7 1,127,526 508,254 276,990 2.01

1 6 222,885 101,210 86,116 1.44

1 5 222,885 160,047 79,213 1.56

1 4 228,600 128,597 85,525 1.51

1 3 1,034,415 749,764 342,069 1.67

1 2 1,028,825 948,002 229,442 2.17

1 1 617,220 311,843 138,330 2.14

2 7 1,028,700 571,001 236,830 2.09

2 6 982,980 461,528 209,305 2.20

2 5 988,820 498,970 197,979 2.28

2 4 977,265 518,555 220,912 2.17

2 3 1,028,700 667,662 211,841 2.27

2 2 965,835 733,025 165,412 2.62

2 1 691,515 416,679 186,469 1.71

3 7 960,120 711,188 109,685 3.83

3 6 954,405 876,558 229,646 1.93

3 5 1,022,985 808,693 284,651 1.70

3 4 960,120 899,470 255,172 1.79

3 3 931,545 1,000,561 243,860 1.89

3 2 944,880 1,004,479 228,074 2.03

3 1 662,940 722,043 183,088 1.76

4 7 942,975 1,051,062 248,903 1.90

4 6 925,830 945,599 267,494 1.71

4 5 946,785 890,039 265,295 1.71

4 4 1,013,460 830,990 290,608 1.70

4 3 1,015,365 745,955 285,755 1.70

4 2 931,545 933,179 374,327 1.22

4 1 668,655 554,822 265,884 1.23

5 7 937,260 982,045 353,262 1.28

5 6 875,477 1,085,549 140,009 2.85

5 5 782,346 1,121,745 298,808 1.24

5 4 737,167 1,046,299 225,425 1.64

5 3 714,286 1,039,638 215,937 1.61

5 2 507,483 692,068 134,233 1.86

5 1 0 10,510 4,226 0.00

6 7 0 326 54 0.00